There are several FAA STCs approved by EASA (i.e. n. 10040937 or n. 10042099) for which it is necessary to apply for a Minor change, too.
It's not related to safety or additional important requirements (as the STC itself gives all the necessary information). It appears to me as business, only business!
You apply for the minor change, pay the fee, get a piece of paper and that's all.
I would like this business to end.
Hi Federica,
We have never had an issue whilst applying EASA approved STCs to our fleet. The only time we need to request EASA validation is when the STC is not EASA approved (classification and fees included, as described) or your product is not on the AML. Could you please tell me where in the regulations do you see a requirement to request anything if the STC is already EASA approved?
I would apply both those STCs without even considering contacting EASA if my products were in the AML and I have no doubt they would pass a NAA audit.
Kind regards,
Dear Federica, the EASA STCs that are applicable to a list of aeroplane models like the ones you have mention (so called AML STCs, where AML stands for Approved Model List) do not need any other minor change to be installed in an aeroplane as long as the model is listed in the AML.
A minor change is required when the STC is installed in other models not approved under the AML STC (models not proposed by the STC applicant). It is needed for safety reasons as the installation might not be the same.
Please note that the minor change route is an option to facilitate the installation of these STCs in models for which the STC holder decided not to investigate. Before this option was made available, a new STC application was needed.
Kind regards.
Dear Cristina,
you are right and probably I should have given more details.
Let's talk about EASA STC 10042099 first.
It allows the installation of a Concorde battery instead of a Gill one and it's a really good improvement.
On the AML list I can find all the Cessna models except the Reims ones.
Investigating I found some information on the FAQ 19374 dated 2013 (https://www.easa.europa.eu/faq/19374) which reports as follow:
“How does EASA deal with STCs on Reims-built Cessna models?
TCs approved on US-built Cessnas and their applicability to Reims-Cessna models.Reims-Cessna was a French company that manufactured US-designed Cessna aircraft under licence. These included the F150, F152, F172, F177, F182, F337, F406 and their variants. These aircraft were identical to the US-built aircraft but the French aircraft were given DGAC Type Certificates. For this reason, FAA STCs approved for US-built Cessna models do not formally apply to Reims-Cessna models; this also applies to validated STCs.
However, because the Reims-Cessna aircraft are identical to the US-built aircraft, and because there is no technical investigation necessary to extend the applicability of STCs to the French-built aircraft, EASA can extend the grandfathered approval to Reims-built aircraft but the approval has to be legally recorded.
The mechanism that is used is the minor change, even if the modification would normally be classified as STC (ie, a major change). The applicant should apply on an EASA Form 32 referring to the FAA STC and its EASA grandfathered approval in the application.
Note that all Reims-Cessna models are now covered under FAA Type Certificates, with the exception of the FTB337G and GA which are covered by EASA SAS and the F406, which is still the responsibility of Reims Aviation Industries (RAI)”
It's funny that if I want to install a Concorde battery on a F150J and on a 150M that have same year of construction, same Service Manual and same configuration, for the first I have to apply for a Minor Change.
If we have a look to the EASA STC 10040937, it's related to the installation of an oil filter adapter to install a spin-on filter instead of a fix one. The STC refer to the engine but EASA requires a minor change for the a/c.
The EASA professional I dealt with wrote me "We’ll discuss internally how we can improve in order to avoid useless change approvals".
In my opinion both EASA STCs require useless change approvals, don't they?!?
Thanks again for your kind attention
Federica
Can you not use Standard Change CS-SC037a (EXCHANGE OF A MAIN AIRCRAFT BATTERY) rather than STC 10042099?
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